Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Claim of expenditure towards premium paid on forward covers of foreign exchange rates - Section 43A is not applicable to the facts of the present case since it is not the case of the Revenue that the foreign exchange loan has been taken for purchasing any asset outside the country. - assessee is entitled to claim the amortization of premium paid on foreign exchange contracts - AT
Claim of expenditure towards premium paid on forward covers of foreign exchange rates - Section 43A is not applicable to the facts of the present case since it is not the case of the Revenue that the foreign exchange loan has been taken for purchasing any asset outside the country. - assessee is entitled to claim the amortization of premium paid on foreign exchange contracts - AT
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